Postern Hill Camping Ltd (“Postern Hill Camping”, “we”, “us” or “our”) is a limited liability company incorporated in England and Wales with company number 14125380. Our registered office is 5 The Witheys, Northampton, NN4 5BR. This policy sets out the basis on which your personal data will be processed by us when you use our websites
www.posternhillcampingco.uk and /or our services.
References to “you” or “your” are to you as an individual using our websites or otherwise with whom we are in contact (whether on behalf of yourself, another individual or organisation).
1 IMPORTANT INFORMATION
It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2 BASIS FOR PROCESSING PERSONAL DATA
2.1 Sections 2.2 – 2.10 explain the purposes for which we may process personal data as a controller, as well as the legal basis on which this processing is carried out.
2.2 To provide services to you: Where you request information about or make a reservation, we may process your personal data in connection with such enquiry or reservation. We may use your personal data to register you as a visitor or prospective visitor at our campsite, to be in contact with you, or for other reasons relating to your interest in and use of our campsite. Our use of your personal data in this way includes sharing your personal data with our employees and other personnel, including third parties we have selected to help us operate our campsite.
The legal basis for using your information in this way is that it is necessary for the performance of a contract with you. If you do not provide us with the personal data, we request from you in connection with a reservation or prospective reservation at our campsite, we may not be able to fulfil that reservation or provide you with the information that you require in connection with a prospective reservation.
2.3 To provide information to you: We may process personal data relating to you or another individual in order to respond to general or specific enquiries, however communicated, which may have been sent by you on your own behalf or in your capacity as an employee or representative of a business or organisation.
The legal basis on which we process an individual’s personal data in these circumstances is that it is necessary for the purposes of our legitimate interests in assisting you with queries, growing our business and to providing good customer service.
2.4 To make our websites better: We may process your personal data in order to provide you with a more tailored user experience, including using your personal data to make sure our websites are displayed in the most effective way for the device you are using. This processing means that your experience of our websites will be more tailored to you. We also use various cookies to help us improve our websites (more details are set out in section 5) and may share your personal data with the third-party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also process personal data for the purposes of making our websites more secure, and to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The legal basis on which we process personal data in these circumstances is that the processing is necessary for the purposes of our legitimate interests in providing you with the best customer experience we can, keeping our websites updated and relevant, and studying how individuals use our services, to inform our marketing strategy and to ensure that each of our websites is kept secure.
2.5 If our business is sold: We will transfer your personal data to a third party:
2.5.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or
2.5.2 if Postern Hill Camping or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the assets transferred to the purchaser,
in each case, the legal basis on which we process your data in these circumstances is that the processing is necessary for the purposes of our legitimate interests in ensuring our business can be continued by a purchaser. If you object to our use of personal data in this way, the relevant seller or buyer of our business may not be able to provide the campsite (and related) services to you.
The legal basis on which we process personal data in these circumstances is that we have a legal obligation to remain transparent in our use of personal data and to ensure you are kept updated on how and why we process your personal data.
2.7 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2.8 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
2.9 Please note that we may process your personal data without knowledge or consent, where this is required or permitted by law.
2.10 In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
3 CATEGORIES OF INFORMATION WE COLLECT FROM YOU
3.1 We will collect and process the following personal data about you.
3.2 Information you give us: You shall provide personal data when corresponding with us via the website or by post, phone, email or otherwise in connection with and your use of our campsite. This includes personal data provided to us when you:
3.2.1 enquire about a reservation via our website, via email or by telephone.
3.2.2 make a reservation at our campsite via our website, via email or by telephone.
3.2.3 visit our website.
3.2.4 meet with one of our members of staff.
3.2.5 request marketing and publications to be sent to you: or
3.2.6 provide us with feedback on our services.
The information you give us may include your name, address, email addresses, phone numbers and age range (and may also include the personal data of the members of your camping group).
3.3 Online Information we collect: With regard to each of your visits to our website, we will automatically collect the following information:
3.3.1 technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
3.3.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
3.4 Information we receive from other sources: We may receive personal data about you from various other third parties and public sources as set out below:
3.4.1 name and related information from our official partners.
3.4.2 third party companies who provide certain services to you on our behalf; and
3.4.3 technical and website usage data from analytics providers, such as Google, based outside the UK.
3.5 We do not actively collect any special categories of personal data about you. This includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation.
4 CATEGORIES OF RECIPIENTS OF PERSONAL DATA
4.2 Your personal data may be shared by us with categories of recipients that include our official business partners and other external third parties who provide support integral to the provision of our services and enable us to operate, such as:
4.2.1 Service providers acting as processors based in the UK who provide IT or system administration services.
4.2.2 Marketing and public relations companies based in (and outside) the UK, in particular social media organisations such as Facebook, Instagram, Twitter and YouTube.
4.2.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.
4.2.4 Third party companies who provide certain services to you on our behalf.
4.2.5 Other third party companies where we have an agreement in place and only where an individual has agreed that we may share their personal data with them.
5.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of their computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.
Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and volumes of usage. This to ensure that the service is available when you want it and fast. More information: http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html#cookiesSet
Social media and Google remarketing
We use technologies such as cookies and conversion pixels from vendors such as Google, Facebook and Twitter to customise content and advertising, to provide social media content that is more relevant, and to analyse traffic to the site. We also share information about your use of our site with our trusted social media, advertising and analytics partners.
These cookies or conversion pixels enable us to build audiences from our website for advertising campaigns served on Google Content Network and social networks. By visiting our site, a relevant advert may appear in your social feeds or as a paid search result on Google. More information:
5.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) they may not be able to access all or parts of our website.
5.5 Except for essential cookies, all cookies will expire as outlined under the expiration column in the table included in paragraph 5.2.
6.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
6.2 You will receive marketing communications from us if you have requested information from us or stayed at our campsite and you have not opted out of receiving that marketing.
6.3 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
6.4 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
7 DATA SECURITY
7.1 We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to individuals’ personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions, and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify the individuals involved and any applicable regulator of a breach where we are legally required to do so.
8 DATA RETENTION
8.1 We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.3 We will generally retain our customers’ data for a period of 7 (seven) years after the contract to which is applied has ended, to ensure that we are able to assist should they have any questions or feedback in relation to our services or to protect, or defend, our legal rights, or for tax purposes.
8.4 Where we have processed personal data to provide you with marketing communications, we may contact you to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).
8.5 Where we have processed personal data for any other reason (such as where you have contacted us with a question in connection with our campsite but have not made a reservation), we will retain your data for twelve (12) months.
8.6 In some circumstances you can ask us to delete your data: see section 9.1.3 below for further information.
8.7 In some circumstances we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 YOUR LEGAL RIGHTS
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:
9.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
9.1.2 Request correction of the personal data that we hold about you. This enables individuals to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data they provide to us.
9.1.3 Request erasure of your personal data. This enables individuals to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal data to comply with local law. Note, however, that we may not always be able to comply with an individual’s request of erasure for specific legal reasons which will be notified to them, if applicable, at the time of their request.
9.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Individuals also have the right to object where we are processing their personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process an individual’s information which override their rights and freedoms.
9.1.5 Request restriction of processing of your personal data. This enables individuals to ask us to suspend the processing of their personal data in the following scenarios: (a) if they want us to establish the data’s accuracy; (b) where our use of the data is unlawful but they do not want us to erase it; (c) where they need us to hold the data even if we no longer require it as they need it to establish, exercise or defend legal claims; or (d) they have objected to our use of their data but we need to verify whether we have overriding legitimate grounds to use it.
9.1.6 Request the transfer of your personal data to you or to a third party. We will provide to individuals, or a third party they have chosen, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which they initially provided consent for us to use or where we used the information to perform a contract with the individual.
9.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the individual withdrew their consent. If an individual withdraws their consent, we may not be able to provide certain services to them. We will advise the individual if this is the case at the time, they withdraw their consent.
If you wish to exercise any of the rights set out above, please contact us directly.
Individuals have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.